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On March 1, FinCEN announced a Notice of Proposed Rulemaking to revise certain provisions in the rules related to the filing of Reports of Foreign Bank and Financial Accounts (FBAR). The proposed rule would, among other things, (i) remove provisions allowing limited account information to be reported when a filer has at least 25 foreign financial accounts; (ii) clarify and expand exemptions for officers and employees of institutions maintaining signature or other authority over accounts, but have no financial interest in such accounts; (iii) require institutions to maintain a list of the officers and employees with signature authority over accounts; (iv) amend the filing date for FBAR reports due in 2016; and (v) revise the FinCEN Form 114 instructions, which outline the BSA electronic filing requirements. Due to potential regulatory changes, FinCEN previously issued temporary notices to extend reporting deadlines for certain filers submitting FBARs.

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